Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 614

Declaration of Harold J. McElhinny in Support of Apple's Motion to Compel Production of Documents and Things filed byApple Inc.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Jacobs, Michael) (Filed on 1/11/2012)

Exhibit E

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December 28, 2011

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Via E-Mail ([e-mail])
Marissa Ducca
Quinn Emanuel
1299 Pennsylvania Ave. NW, Suite 825
Washington, D.C. 20004
Re:

Apple v. Samsung, Case No. 11-cv-1846-LHK (PSG) (N.D. Cal.)

Dear Marissa:
Apple requests that Samsung agree to substantially complete, by January 23, 2012, its
production of sketchbooks, CAD, and physical models to the extent not already covered by
my December 6, 2011 letter and the Court’s December 22, 2011, Order, as follows:
All Samsung sketchbooks (or similar hand drawings, however created, stored, or
archived) depicting designs for any Samsung phone product, tablet product, or
touchscreen digital media player, regardless of where sold, whether for a final design
or an alternative design that was not commercially released.
All CAD drawings (or other schematics that Samsung uses to design its products)
depicting designs for any Samsung phone product, tablet product, or touchscreen
digital media player, regardless of where sold, whether for a final design or an
alternative design that was not commercially released.
All physical models depicting designs for any Samsung phone product, tablet
product, or touchscreen digital media player, regardless of where sold, whether for a
final design or an alternative design that was not commercially released.
Products currently under development and not yet released may be omitted. Apple will add
this to the agenda for the lead counsel meet-and-confer expected next week, unless the
parties reach agreement upon the scope and timing of this production in advance.
Sincerely,
/s/ Mia Mazza
Mia Mazza

sf-3088216